Legal Bulletin



Expenses paid in connection with agreements for the importation of technology, patents and trademarks, may be tax-deducted even if the term of the agreement is extended, and the registry of such extension is filed extemporaneously 

In the event in which there is a renewal or extension of the duration of the agreement, the law does not fix a term to carry out the registration of such extension


In its Ruling of June 1st, 2016, the Supreme Court on Administrative Matters, referred to the possibility of deducting payments made abroad, for cases in which there is a renewal or extension of the term of agreements for importation of technology that were originally registered before the Tax Authority, but no register of the extension has been made.

The Supreme Court of Administrative Matters argues that it must be established whether the agreement was registered prior to the application of the benefit provided by law. However, in cases where a renewal of the registered agreement is required, there is no provision that determines a deadline for making such registry.

In this sense, as there is no fixed term for registering renewals or extensions of the aforementioned agreements, and taking into account that tax rules do not provide a consequence for not making such register on a given time, the right of the taxpayer to request the tax-deduction of such payments is not affected.